# Document Control Officer Office of Pollution Prevention and Toxic Substances, 7407 U .S. EPA 1201 Constitution Ave., NW Washington, DC 20460 June 22, 2005 

# /I=u ./ A41' 04"~ 

# ,)65- 63q 

# CD

W RE: Premanufacture Notice TS-05CR01 c~ co 

# I Dear Sir or Madam

: On behalf of the [ ] is hereby submitting in accordance with 40 CFR Section 720 .50the attached Premanufacture Notice (PMN) TS-05CR01 for review . In accordance with 40CFRSection 700 .45(b), the fee of $2,500.00 has been submitted (see attached copy of check) . This PMNnotification contains confidential business information (CBI) . Accordingly, in addition to the submission of the original notification and two copies, a single sanitized copy is also provided. Finally, the PMNformused is an electronic version purchased from CMA . The document showing EPA approval of the formis attached. If there are any questions regarding this submission, please do not hesitate to contact me at [ ] . Sincerely,



# l[ Attachments 

# ] Company Sanitized c.~

## U .S. ENVIRONMENTAL PROTECTION AGENCY 

# : .FpA

TEST DATA ANDOTHER DATA 

# PREMANUFACTURE NOTICE

You are required to submit all test data in your possession or control and to provide a description ofall other data known to or reasonably ascertainable by you, if these data are related to the health and environmental effects on the manufacture, processing, distribution in commerce, use, ordisposal ofthe new chemical substance

. Standard literature citations may be submitted for data in the open scientific literature. Complete test data (written in English), not summaries of data, must be submitted ifthey do not appear in the open literature. Youshould clearly identify whether test data is on the substance or on an analog. Also, the chemical composition of the tested material should be characterized. Following are examples of test data and other data. Data should be submitted according to the requirements of §720 .50of thePremanufacture Notification Rule (40 CFRPart 720) . 

# Zh*any Sanitized

i rnter the total number ot pages n the Premanufacture Notice 

## GENERAL INStittftTIONS

. You must provide all information requested in this formto the extent that it is known to or reasonably ascertain have actual data. 

# AGENCY USE ONLY

ble by you. Make reasonableWmates ifyou do not Before you complete this form, you should read the "Instructions Manual for Premanufacture Notification" (the Instructions Manual is available from the Toxic Substances Control Act (TSCA) Information Service by calling 202-554-1404, or faxing 202-554-5603) . If a user fee has been remitted for this notice (40CFR700 .45), indicate in the boxes above the TS-user fee identification number you have generated. Remember, your user fee ID number must also appear on your corresponding fee remittance, which is sent to EPA, HQAccounting Operations Branch (PM-226, P .O. 360399M, Pittsburgh, PA 15251-6399, Ann. TSCA User fee. Part I-GENERAL INFORMATION You must provide the currently correct Chemical Abstracts (CA) Name of the new chemical substance, even if you claimthe identity as confidential . You may authorize another person to submit chemical identity information for you, but your submission will not be complete and the reviewwill not begin until EPA receives this information. A letter in support of your submission should reference your TS user fee identification number. You must submit an original and two copies ofthis notice including all test data. If you claimed any information as confidential, a single sanitized copy must also be submitted. Part II-HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE If there are several manufacture, processing, or use operations to be described in Part Il, sections A and B of this notice, reproduce the sections as needed. Part III- LIST OF ATTACHMENTS Attach additional sheets if there is not enough space to answer a question fully. Label each continuation sheet with the corresponding section heading. In Part III, list these attachments, any test data or other data and any optional information included in the notice. Test Data (Check Below any included in this notice) Environmental fate data 0 Yes " Other data ® Yes " Health effects data 0 Yes Risk assessments " Environmental effects data [I Yes Structure/activity relationships OPTIONAL INFORMATION You may include any information that you want EPA to consider in evaluating the new substance. On page 11 ofthis form, space has been provided for you to described pollution prevention and recycling information you may have regarding the new substance. So-called "binding" boxes are included throughout this formfor you to indicate your willingness to be bound to certain statements you make in this section, such as use, production volume, protective equipment . . . This option is intended to reduce delays that routinely accompany the development of consent orders or Significant New Use Rules . Except in the case ofexemption applications (such as TMEA, LVE, LOREX) where certain information provided in such notification is binding on the submitter when the Agency approves the exemptionapplication, checking a binding box in this notice does not by itself prohibit the submitter fromlater deviating fromthe information (except chemical identity) reported inthe form . CONFIDENTIALITY CLAIMS You may claimany information in this notice as confidential . To assert a claim on the form, mark (X) the confidential box next to the information that you claim as confidential . To assert a claimin an attachment, circle or bracket the information you claim as confidential . Ifyou claiminformation in the notices as confidential, you must also provide a sanitized version of the notice. (includina attachments) . For additional instructions on claiming information as confidential, read the Instructions Manual . ® Mark (x) if any information in this notice is claimed as confidential . EPA FORM

7710-25 (Rev. 5-95) Physical/Chemical Properties* ® Yes Test data not in the possession or control of the submitter * A physical and chemical properties worksheet is located on the last page of this form . TYPE OF NOTICE (Check Only One) c~ ® 

## D. 2

FormApproved. O

.M .B. No. 2070-0012. Approval Expires 10-31-96. Date of receipt

PMN (Premanufacture Notice) crl C= INTERMEDIATE PMN (submitted in sequence with finQl .producTPI4Nj C? --1 SNUN (Significant New Use Notice) TMEA (Test Marketing Exemption Application) .,_ .., - '- LVE (Low

Volume Exemption) @ 40 CFR 723.50(c)(IbD LOREX (Low

Release/LowExposure Exemption) @ 40 CFR 723.50(c)(2) LVE Modification IS THIS A CONSOLIDATED PMN? # ofchemicals LOREX Modification Yes (Prenotice Communication # required, enter # on page 3) Replaces previous editions of EPA Form7710-25.



# e ,:2Y Q, ~ 7 . ~

### Public reporti,ng burden for this collection of information is estimated to average 110 hours per response, including time for reviewing instructions,

searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding the burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden, to Chief, Information Policy Branch, PM-223, U.S. Environmental Protection Agency, 401 M . St ., S.W

., Washington, D.C. 20460; and to the Office of Management and Budget, Paperwork Reduction Act (2070-0012), Washington, D.C. 20503. 

# CERTIFICATION I certify that to the best of my knowledge and belief: 1 . Thecompany named in Part 1, section A, subsection la of this notice formintends to manufacture or import for a commercial purpose, other than in small quantities solely for research anddevelopment, the substance identified in Part 1, Section B. 2. All information provided in this notice is complete and truthful as of the date of submission. 3 . I amsubmitting with this notice all test data in my possession or control and a description of all other data known to or reasonably ascertainable by me as required by §720.50of the Premanufacture Notification Rule. Additional Certification Statements: If you are submitting a PMN, Intermediate PMN, Consolidated PMN, or SNUN, check the following user fee certification statement that applies: ®The Company named in Part I, Section Ahas remitted thefee of $2500specified in 40 CFR700 .45(b), or 0 The Company named in Part I, Section Ahas remitted the fee of $1000for an Intermediate PMN (defined @40CFR 700 .43) in accordance with 40 CFR700 .45(b), or The Company named in Part I Section Ais a small business concern under 40 CFR 700 .43 and has remitted a fee of $100 in accordance with 40 CFR700 .45(b) . If you are submitting a low volume exemption (LVE) application in accordance with 40 CFR723.50(c)(1) or a Low release and low exposure exemption (LoRex) application in accordance with 40 CFR 723.50(c)(2), check the following certification statements: The manufacturer submitting this notice intends to manufacture or import the new chemical substance for commercial purposes, other than in small quantities solely for research and development, under the terms of 40 CFR 723.50 . 0 The manufacturer is familiar with theterms of this section and will comply with those terms; and 0The new

chemical substance for which the notice is submitted meets all applicable exemptionconditions. 0If this application is for an LVE in accordance with 40 CFR 723.50(c)(1), the manufacturer intends to commence manufacture of the exempted substance for commercial purposes within 1 year of the date of the expiration of the 30 day review period. The accuracy of the statements you make in this notice should reflect your best prediction of the anticipated facts regarding the chemical substance described herein. An knowing and willful misinterpretation is subject to criminal p enalt y pursuant to 18 USC 1001. Confidential Signature and title ofAuthorized Official (Original Signature Required) Date 

## X Signature of agent - (if applicable) Date 

## X 3

EPA FORM

7710-25 (Rev. 5-95)

## Part I -- GENERAL INFORMATION

Section A -- SUBMITTER IDENTI FICATION 1a. Person Name ofauthorized official Position Submitting Notice (in U

.S .) Company Mailing address (number and street) 

### City, State, ZIPCode b. Agent (if Name of authorized official Position applicable) X

Company Mailing address (number and street) City, State, ZIPCode Telephone Area Code Number

c . If you are submitting this notice as part of ajoint submission, mark (X) this box. Joint Submitter (if Name of authorized official Position applicable) Company

Mailing address (number and street) City, State, ZIPCode Telephone Area Code Number 2. Technical Name of authorized official Position Contact (in X 

### U.S.) Company

Mailing address (number and street) City, State, ZIP Code Telephone Area Code Number 3. If you have had a prenotice communication (PC) concerning this notice and EPA assigned a PC Number to the notice, enter the number. Mark (X) --i if none 4. Ifyou previously submitted an exemption application for the chemical substance covered by this notice, enter the exemption number assigned by EPA If i l i b d PMNf i Mark (X) -- El X . you prev ous y su m tte a or th s substance enter the if none PMN number assigned by EPA (i .e. withdrawn or incomplete) .--~ 5 . Ifyou have submitted a notice of Bona fide intent to manufacture or import for the chemical substance covered by this notice, enter the notice number assi ned b EPA Mark (X) -- El 

### X g y . -~ if none 6 . . ~ Type of Notice - Mark (X) 1 Manufacture 2. ® Import Only Only 3. ~ Both Binding Option ~ Binding Option Marx (X) 

### Mark Qthe "Confidential" box next to an subsection you claimas confidential Confidential

EPAFORM

7710-25 (Rev. 5-95) Pao,-Y

## p. 5 Part I -- GENERAL INFORMATION-- Continued Section B-- CHEMICAL IDENTITY INFORMATION : You must provide a currently correct Chemical Abstracts (CA) name of the substance based on the ninthCollective index (9Cl) of CA nomenclature rules and conventions. 

### Mark (X) the "Confidential" box next to an itemyou claimas confidential Complete either item1 (Class 1 or 2substances) or 2(Polymers) as appropriate. Complete all other items . Ifanother person will submit chemical identity information for you (for either Item1 or 2), mark (X) the box at the right. ConfiIdentif the name, com pany, and address of that p erson in a continuation sheet. 0 dential 1 . Class 1 or 2chemical substances (for definitions ofclass 1 and class 2substances, see the Instructions Manual) a . Class of substance - Mark (X) 1 [:] Class 1 or 2 [:] Class 2 b . Chemical name (Currently correct Chemical Abstracts (CA) Name that is consistent with TSCA Inventory listings for similar substances. For Class 1 substances a CA Index Name must be provided. For Class 2 substances either a CA Index Name or CA Preferred Name must be provided, which ever is appropriate based on CA 9CI nomenclature rules and conventions) .

c. Please identify which method you used to develop or obtain the specified chemical identity information reported in this notice: (check one). ® Method 1 (CAS Inventory Expert Service - a copy of the Identification E] Method 2(Other Source) report obtained fromthe CAS Inventory Expert Services must be submitted as an attachment to this notice) d. Molecular formula and CASRegistry Number (if a number already exists for the substance) 

## X CAS# - 

## X e . For a class 1 substance, provide a complete and correct chemical structure diagram . For a class 2 substance - (1) List the immediate precursor substances with their respective CAS Registry Numbers. (2) Describe the nature of the reaction or process. (3) Indicate the range ofcomposition and the typical composition (where appropriate) . (4) Provide a correct representative or partial chemical structure diaQram, as complete as can be known, if one can be reasonablv ascertained.

® Mark (X) this box if you attach a continuation sheet. EPAFORM

7710-25 (Rev. 5-95) Pag ,5-A-

# Page,4-°

### Paae ~

## p. 8 Part I -- GENERAL INFORMATION-- Continued Section B -- CHEMICAL IDENTITY INFORMATION-- Continued 2. Polymers (For a definition of polymer, see the Instructions Manual .) Confi

### dential a. Indicate the number-average weight of the lowest molecular weight composition of the polymer you intend to manufacture. Indicate maximum

weight percent of low molecular weight species (not including residual monomers, reactants, or solvents) below 500and below1,000absolute molecular weight of that composition. Describe the methods of measurement or the basis for your estimates: GPC ~ Other Ej : (Specify) not applicable

i) lowest number average molecular weight: ii) maximum

weight %

below500molecular weight: iii) maximum

weight %

below1000 molecular weight: Mark (X) this box if you attach a continuation sheet. b. You must make separate confidentiality claims for monomer or other reactant identity, composition information, and residual information. Mark (X) the "Confidential" box next to any itemyou claim as confidential (1) - Provide the specific chemical name and CAS Registry Number (if a number exists) of each monomer or other reactant used in the manufacture of

the polymer. (2) - Mark (X) this column if entry in column (1) is confidential . (3) - Indicate the typical weight percent ofeach monomer or other reactant in the polymer. (4) - Mark (X) the identity column if you want a monomer or other reactant used at two weight percent or less to be listed as part ofthe polymer

description on the TSCA Chemical Substance Inventory. (5) - Mark (X) this column ifentries in columns (3) and (4) are confidential . (6) - Indicate the maximum weight percent of each monomer or other reactant that may be present as a residual in the polymer as manufactured for commercial purposes. (7) - Mark (X) this column ifen in column (6) is confidential . Monomer or other reactant and CASRegistry Number Confi- Typical Identity Confi- Maximum Confidential composition Mark (X dential residual dential (1) (2) (3) (4) (5) (6) (7) %

% % %a % % % Mark (X) this box if you attach a continuation sheet. c. Please identify which method you used to develop or obtain the specified chemical identity information reported in this notice (check one) .

Method 1 (CAS Inventory Expert Service - a copy of the identification report ~ Method 2(other source) obtained fromCAS Inventory Expert Service must be submitted as as attachment to this notice) d. Thecurrently correct Chemical Abstracts (CA) name for the polymer that is consistent with TSCA Inventory listings for similar polymers . e. Provide a correct representative or partial chemical structure diagram, as complete as can be known, if one can be reasonably ascertained.

~ Mark (X) this box ifyou attach a continutation sheet. EPA FORM

7710-25 (Rev. 5-95) Pagv<

## p. 9 

# Part I -- GENERAL INFORMATION-- Continued Section B-- CHEMICAL IDENTITY INFORMATION -- Continued 3. Impurities (a) - Identify each impurity that may be reasonably anticipated to be present in the chemical substance as manufactured for commercial purpose . CASRegistry Number if available . Ifthere are unidentified impurities, enter "unidentified ." (b) - Estimate the maximum wei g ht % of each im

p urity. If there are unidentified im p urities, estimate their total wei g ht % . Provide the Impurity and CAS Registry Number



### (a) Maximum percent (b) Confidential % % % % % % % ® Mark (X) this box if you attach a continuation sheet. 4 . Synonyms - Enter any chemical synonyms for the new chemical identified in subsection 1 or 2. Confidential Mark (X) this box ifyou attach a continuation sheet. 

## X

5. Trade identification - List trade names for the new chemical substance identified in subsection 1 or 2.

Mark (X) this box if you attach a continuation sheet. 

### X

6 . Generic chemical name - Ifyou claim chemical identify as confidential, you must provide a generic name for your substance that reveals the specific chemical identity of the new chemical substance to the maximum extent possible. Refer to the TSCA Chemical Substance Inventory, 1985 Edition, Appendix Bfor guidance on developing generic names. Metal silicate

Mark (X) this box if youattach a continuation sheet. 7. Byproducts - Describe any byproducts resulting from the manufacture, processing, use, or disposal ofthe new chemical substance. Provide the CASRegistry Number if available. Byproduct (1) CAS Registry Number (2) Confidential 

# X

Mark (X) this box if you attach a continuation sheet. EPA FORM

7710-25 (Rev. 5-95) Page,,6'

## p. 10

Page

## p. 11 

# Part I -- GENERAL INFORMATION-- Continued Section C-- PRODUCTION, IMPORT, ANDUSE INFORMATION : Mark (X) the "Confidential" box next to an itemyou claimas confidential . 1 . Production volume -- Estimate the maximum production volume during the first 12 months of production. Also estimate the maximum production volume for any consecutive 12-month period during the first three years of production. Estimates should be on 100% new chemical substance basis. For a Low Volume Exemption application, ifyou choose to have your notice reviewed at a lower production volume than 10,000 k / r, specify the volume and mark (x) in the binding box. If ranted, you are bound to this volume 

## Maximum

first 12-month production (kg/yr) (100%new

chemical substance basis) Maximum12-month production (kgfyr) (100%new

chemical substance basis) Contidential Binding

Option Mark (x) 

## X 2. Use Information --You must make separate confidentiality claims for the description ofthe category of use, the percent of production volume devoted to each category, the formulation of the new substance, and other use information. Mark (X) the "Confidential" Box next to any item you claimas confidential . a. (1) -- Describe each intended category of use of the newchemical substance by function and application. . (2) -- Mark (X) this column if entry column (1) is confidential business information (CBI) . (3) -- Indicate your willingness to have the information provided in column (1) binding. 

## (4) -- Estimate the percent of total production for the first three years devoted to each category of use. (5) -- Mark (X) this column if entry in column (4) is confidential business information (CBI) . (6) -- Estimate the percent of the new substance as formulated in mixtures, suspensions, emulsions, solutions, or gels as manufactured for commercial purposes at sites under your control associated with each category of use. (7) -- Mark (X) this column if entry in column (6) is confidential business information (CBI) . (8) -- Indicate %of product volume expected for the listed "use" sectors. Mark more than one box if appropriate. Mark (X) to indicate your willingness to have the use type provided in (8) binding. (9) -- Mark (X) this column if entry(ies) in column (8) is (are) confidential business information (CBI) . Category of use (1) CBI Binding Option Production % CBI %inFormCBI % of substance expected per use

(8) CBI (by function and application i .e. a dispersive dye

for finishing pol y

ester fibers) (2) M~k (xl (3) (4) (5) ulation (6) (7) Sitelimited Con-*

sumer Industrial Commercial Binding

O p tion (9)

* If you have identified a "consumer" use, please provide on a continuation sheet a detailed description ofthe use(s) ofthis chemical substance in consumer products. In addition include estimates ofthe concentration of the new chemical substance as expected in consumer products and describe the chemical reactions by which this substance loses its identity in the consumer product. E]Mark (X) this box ifyouattach a continuation sheet. b. Generic If you claim any category of use description in subsection 2a as confidential, enter a generic description of that category. Read the use Instructions Manual for examples of generic use descriptions. 

### description 

## toner additive

~ Mark (X) this box ifyou attach a continuation sheet. 3 . Hazard Information -- Include in the notice a copy of reasonable facsimile ofany hazard warning statement, label, material safety data sheet, or other informationwhich will be provided to any person who is reasonably likely to be exposed to this substance regarding protective equipment or practices for the safe handing, transport, use, or disposal of the new substance. List in part III hazard information you include. Binding Option Mark (x) ® Mark (X) this box if youattach hazard information . EPAFORM

7710-25 (Rev. 5-95) Page /11i

## p. 12 

# Part II-- HUMANEXPOSURE ANDENVIRONMENTAL RELEASE Section A-- INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER Mark (x) the "Confidential" box next to any itemyou claim as confidential 

### Complete section A for each type of manufacture, processing, or use operation involving the new chemical substance at industrial sites you control . Importers do not have to complete this section for operations outside the U.S. ; however, you may still have reporting requirements if 

## there are further industrial processingor use o perations after im

p ort. You must describe these o perations. See instructions manual 1 . Operation description Confia. Identit y -- Enter the identity of the site at which the op eration will occur. dential Name 

## not applicable, PMN substance will be imported Site address (number and street) City, County, State, ZIP code 

### If the same operation will occur at more than one site, enter the number of sites. Identify the additional sites on a continuation sheet, and if any of the sites have significantly different production rates or operations, include all the information requested in this section for those sites as attachments.

Mark (X) this box if you attach a continuation sheet. 

### b. Type -- Mark (X) E]Manufacturing OProcessing E]Use 

## c. Amount and Duration -- Com p lete 1 or 2 as appropriate Maximum

kg/batch (1oo%new

chemical Hours/batch Batches/year substance) 1 . Batch Maximum kg/batch (100%mw

cheirieal Hours/batch Batches/year substtnce) 2 . Continuous d. Process description 0 Mark (X) to indicate your willingness to have your process description binding. (1) Diagram

the major unit operation steps and chemical conversions. Include interim storage and transport containers (specify- e.g. 5 gallon pails, 55 gallon drum, rail car, tank truck, etc.). (2) Provide the identity , the approximate weight (by kg/day or kg/batch on a 100%new chemical substance basis), and entry point ofall starting materials and feedstocks (including reactants, solvents, catalysts, etc.), and of all products, recycle streams, and wastes. Include cleaning chemicals (note frequency if not used daily or per batch .) . (3) Identify by number the points of release, including small or intermittent releases, to the environment of the new chemical substance. 

## not applicable, PMN substance will be imported

~ Mark (X) this box if you attach a continuation sheet. EPAFORM

7710-25 (Rev. 5-95) Pag51'r 

## l~

# . Tart II-- HUMANEXPOSURE AND ENVIRONMENTAL RELEASE -- Continued

Section A -- INDUSTRIAL SITES CONTROLLED BY THESUBMITTER-- Continued 2 . Occupational Exposure -- You must make separate confidentiality claims for the description of worker activity, physical form of the new

chemical substance, number of works exposed, and duration of activity. Mark (X) the "Confidential" box next to any itemyou claim as confidential . (1) --Describe the activities (i .e. bag dumping, tote filling, unloading drums, sampling, cleaning, etc.) in which workers may be exposed to the substance . (2) --Mark (X) this column if entry in column (1) is confidential business information (CBI) . (3) -- Describe any protective equipment and engineering controls used to protect workers. (4) and (6) -- Indicate your willingness to have the information provided in column (3) or (5) binding. (5) -- Indicate the physical form(s) of the new chemical substance (e.g., solid: crystal, granule, powder, or dust) and % new chemical substance (ifpart ofa mixture) at the time ofexposure. (7) --Mark (X) this column if entry in column (5) is confidential business information (CBI) . (8) -- Estimate the maximum number of workers involved in each activity for all sites combined. (9) --Mark (X) this column if entry in column (8) is confidential business information (CBI) . (10) and (11) -- Estimate the maximum duration of the activity for any worker in hours per day and days per year . (12) --Mark (X) this column if entries in columns (10) and (11) are confidential business information (CBI) . Worker activity CBI Protective Equipment/ Binding Physical forms(s) Binding CBI # of CBI Maximu m duration CBI (i .e., bag dumping, filling drums) Engineering Controls Option and % new Option Worker Hrs/day Days/yr Mark (x) substance Mark (x) (1) (2) (3) (4) (5) (6) (7) Expose (9) (l0) (11) d (8) 

## not applicable, PMN substance will be imported

~ Mark (X) this box if you attach a continuation sheet. 3. Environmental Release and Disposal -- You must make separate confidentiality claims for the release number and the amount of the new chemical substance released and other release and disposal information. Mark (X) the "Confidential" box next to each itemyou claim as confidential . (1) --Enter the number ofeach release point identified in the process description, part II, section A, subsection ld(3) . (2) -- Estimate the amount of the new substance released (a) directly to the environment or (b) into control technology (in kg/day or kg/batch) . (3) --Mark (X) this column ifentries in columns (1) and (2) are confidential business information (CBI) . (4) -- Identify the media (stack air, fugitive air (optional-see Instruction Manual), surface water, on-site or off-site land or incineration, POTW, or other (specify)) to which the new

substance will be released fromthat release point. (5) --a . Describe control technology, if any, and control efficiency that will be used to limit the release of the new substance to the environment . For releases disposed of on land, characterize the disposal method and state whether it is approved for disposal of RCRA hazardous waste. On a continuation sheet, for each site describe any additional disposal methods that will be used andwhether the waste is subject to secondary or tertiary on-site treatment. b . Estimate the amount released to the environment after control technology (in kg/day). (6) --Mark (X) this column if entries in columns (4) and (5) are confidential business information (CBI) . (7) --Identify the destination(s) ofreleases to water. Please supply NPDES (National Pollutant Discharge Elimination System) numbers for direct discharges or NPDES numbers ofthe POTW (Publicl Owned Treatment Works) . Mark (X) if the POTW name or NPDES#is confidential business information (CBI) . Release Amount of new substance CBI Media of Control technology and efficiency (you maywish to optionally attach efficiency data) Cut Number released release (1) (2a) (2b) e g A.~ air Binding 

### (3) (4) (Sa) Mark (x) (Sb) (6)



## not applicable, PMN substance will be imported

(7) Mark (X) the El POTW provide name(s) below : CBI 1:1 Navigable ~ Other -Specify provide NPDES# CBI destination(s) of waterway releases to water. Mark (X) this box ifyouattach a continuation sheet. EPA FORM

7710-25 (Rev. 5-95) Page 1111

## p. 14



# Part II-- HUMANEXPOSURE ANDENVIRONMENTAL RELEASE -- Continued Section B-- INDUSTRIAL SITES CONTROLLED BY OTHERS Complete section Bfor typical processing or use operations involving the newchemical substance at sites you do not control . Importers do not have to complete this section for operations outside the U .S ; however, you must report any processing or use activities after import. See the Instructions Manual . Complete a separate section B

for each type ofprocessing, or use operation involving the new chemical substance. If the same operation is performed at more than one site describe the typical operation common to these sites. Identifyadditional sites on a continuation sheet. 

### 1 . Operation Description -- To claiminformation in this section as confidential, circle or bracket the specific information that you claimas confidential . (1) -- Diagram

the major unit operation steps and chemical conversions, including interim storage and transport containers (specify - e .g. 5 gallon pails, 55 gallon drums, rail cars, tank trucks, etc) . On the diagram, identify by letter and briefly describe each worker activity. (2) -- Provide the identity, the approximate weight (by kg/day or kg/batch, on an 100%new chemical substance basis), and entry point ofall feedstocks (including reactants, solvents and catalysts, etc) and all products, recycle streams, and wastes. Include cleaning chemicals (note frequency if not used daily or per batch) . (3) -- Identify by number the points ofrelease, including small or intermittent releases, to the environment ofthe new chemical substance. (4) Please enter the #of sites (remember to identify the locations of these sites on a continuation sheet) : 

### # of sites 

# See page 10a

® Mark (X) this box if youattach a continuation sheet. 2 . Worker Exposure/Environmental Release (1) -- Fromthe diagram above, provide the letter for each worker activity. Complete 2-8 for each worker activity described . (2) -- Estimate the number of workers exposed for all sites combined. (4) --Estimate the typical duration of exposure per worker in (a) hours per day and (b) days per year . (6) -- Describe physical formof exposure and % new chemical substance (if in mixture), and any protective equipment and engineering controls, if any, used to protect workers. (7) -- Estimate the percent of the new substance as formulated when packaged or used as a final product. (9) -- Fromthe process diagram above, enter the number ofeach release point. Complete 9-13 for each release point identified. (10) -- Estimate the amount of the new substance released (a) directly to the environment or (b) into control technology to the environment (in kg/day or kg/batch) . (12) -- Describe media of release i .e. stack air, fugitive air (optional-see Instructions Manual), surface water, on-site or off-site land or incineration, POTW, or other (specify) and control technology, if any, that will be used to limit the release ofthe new substance to the environment . (14) -- Identify byproducts which may result fromthe operation. (3), (5), (8), (11), (13) and (15) -- Mark (X) this column if an of the proceeding entries are confidential business information (CBI) . Letter # of CBI Duration CBI Protective Equip. / % in CBI Release Amount of CBI Media of Release CBI of Workers of Engineering Controls/ Form- Number New &Control Act- Exposed Exposure Physical Form and % ulation Substance Technology ivity new substance Released (1) (2) (3) (4a) (4b) (5) (6) (7) (8) (9) (l0a) (lOb) (11) (12) (13) 

## see page 10a

L 14) -- Byproducts : (15) 

## none I ® Mark (X) this box if you attach a continuation sheet, EPA FORM

7710-25 (Rev. 5-95) Page 1,11 1'/) 1

## p. 15

## p. 16



# OPTIONAL POLLUTION PREVENTION INFORMATION To claiminformation in this section as confidential circle or bracket the specific information that y ou claimas confidential . 

# In this section you may provide information not reported elsewhere in this formregarding your efforts to reduce or minimize potential risks associated with activities surrounding manufacturing, processing, use and disposal of the PMNsubstance. Please include new information pertinent to pollution prevention, including source reduction, recycling activities and safer processes or products available due to the new chemical substance. Source reduction includes the reduction in the amount or toxicity of chemical wastes by technological modification, process and procedure modification, product reformulation, raw materials substitution, and/or inventory control . Recycling refers to the reclamation of useful chemical components fromwastes that would otherwise be treated or released as air emissions or water discharges, or land disposal . Descriptions of pollution prevention, source reduction and recycling should emphasize potential risk reduction subsequent to compliance with existing regulatory requirements and can be either quantitative or qualitative. The EPAis interested in the information to assess overall net reductions in toxicity or environmental releases and exposures, not the shifting of risks to other environmental media or non-environmental areas (e.g., occupational or consumer exposure) . In addition, information on the relative cost or performance characteristics of the PMNsubstance to potential alternatives may be provided. All information provided in this section will be taken into consideration during the review of this substance. See Instructions Manual and Pollution Prevention Guidance manual for guidance and exam p les. Describe the expected net benefits, such as (1) an overall reduction in risk to human health or the environment; (2) a reduction in the volume manufactured; (3) a reduction in the generation of waste materials through recycling, source reduction or other means; (4) a reduction in potential toxicity or human exposure and/or environmental release; (5) an increase in product performance, a decrease in the cost of production and/or improved operation efficiency of the new chemical substance in comparison to existing chemical substances used in similar application; or (6) the extent to which the new chemical substance may be a substitute for an existing substance that poses a g reater overall risk to human health or the environment.

E] Mark (X) this box if you attach acontinuation sheet. EPA FORM

7710-25 (Rev. 5-95)

## p. 17 

# Part III -- LIST OF ATTACHMENTS Attach continuation sheets for sections of the formand test data and other data (including physical/chemical properties and structure/activity information), and optional information after this page. Clearly identify the attachment and the section of the form to which it relates, if appropriate. Number consecutively the pages of the attachments. In the column below, enter the inclusive page numbers of each attachment . Mark (X) the "Confidential" box next to any attachment name you claimas confidential . Read the Instructions Manual for guidance on how to claimany information in an attachment as confidential . You must include with the sanitized copy ofthe notice form a sanitized version of any attachment in which you claiminformation as confidential . Attachment name Attachment a e number(s) Confidential 

## Material Safety Data Sheet MSDS 

## 14-17 Main properties 13,18 X-ray diffraction chart 19-20 Powder diffraction file 21 Phase diagrams 22 Water elution test 23 CASIES Inventory Report 24 Chemical structure diagram 4a Manufacturing process 4b Impurities list 6a Operation Description 10a CMA electronic PMN formdocumentation 25 PMNfee documentation 26

1:1 Mark (X) this box if you attach a continuation sheet. Enter the attachment name and number . EPAFORM

7710-25 (Rev. 5-95)

## p. 18 PHYSICAL ANDCHEMICAL PROPERTIES WORKSHEET To assist EPA's reviewofphysical and chemical properties data, please complete the following worksheet for data you provide and include it in the notice. Identify the property measured, the page ofthe notice on which the property appears, thevalue of the property, the units in which the property is measured (as necessary), andwhether or not the property is claimed as confidential . The physical state of the neat substance should be provided. These measured properties should be for the neat (100%pure) chemical substance. Properties that are measured for mixtures or formulations should be so noted (% PMNsubstance in -) . You are not required to submit this worksheet; however, EPA strongly recommends that you do so, as it will simplify reviewand ensure that confidential information is properly protected. You should submit this worksheet as a supplement to your submission of test data. This worksheet is not a substitute for submission of test data. Property (a) Mark (X) if provided Page

number (b) Value (~) Measured o Estimate (M or E) Conedenrial Mark (X) (~) 

## Phy sical state of neat substance X 15 X- (s) -(1) -( ) M Vapor pressure @ Tem p erature °C Torr S p ecific g ravity X 16 3.2 M Solubility @ Temperature °C Solvent Solubility in water @

Tem perature °C X 16 insoluble E Melting tem

p erature X 16 1,890 °C M 

# F Boiling / sublimation tem erature@ torr pressure Spectra Dissociation constant Particle size distribution Octanol/water p

artition coefficient Henr y's Law

constant Volitalization fromwater Volitalization fromsoil H@concentration Flammability Ex lodabilit Adsorption / coefficient Other - S

pecify



## ATTACHMENT PAGE, .B"'

## p. 19 

# Material Safety Data Sheet

1 . Chemical Product Identification Material Identification Formula : [ 

# Grade : See Trade names and Synonyms Tr

# ade names and Svnonvms~ 

# 2. Product Composition Product Classification :Magnesium Silicate Components CAS Number Percent 100 3 . Hazard Identification Warning: " May cause mechanical eye irritation. Protective Measures: " Avoid contact with the eyes. " Use in well ventilated areas. " Do not breathe dust. 

# Revised May 17, 2005



# 4. First Aid Measures Inhalation: " Remove person to fresh air. If breathing is difficult, provide oxygen and seek medical attention 

# Eye Contact: " Rinse eyes immediately with water for at least 15 minutes. See a physician. Skin Contact: " Wash skin thoroughly with soap and water. See a physician if irritation persists. Ingestion: " Provide symptomatic treatment and seek prompt medical attention. 

# 5 . Fire Fighting Methods " Flash Point :Not applicable " Method :Not applicable

## p. 20



# Extinguishing Media / Fire Fighting Procedures: " Use the following extinguishing media when fighting fires involving this material : water fog, foam, dry chemical or carbon dioxide. Unusual Hazards: " Normal precautions for dusts should be provided. Avoid high concentrations of dust air. 

# 6 . Accidental Release Measures Release Response: " Minimize dusting. 

# CAUTION

: May cause a slippery condition when wet. Sweep / shovel up and transfer into a suitable container for re-use or disposal . Personal Protective Equipment: " Wear a air-purifying respirator equipped with filters for protection against dusts and mists. Wear cotton or canvas gloves. Wear safety glasses. 7 . Handling And Storage Handling: " Avoid high concentrations of dust in air through the use ofventilation or other suitable controls. Storage: " This material is not hazardous under normal operating conditions . 8 . Exposure Control Information Occupational Exposure Limits : ACGIH-TLV OSHA-PEL Forsterite Not applicable Not applicable Engineering Control Measures: 

# " Use local exhaust ventilation if airborne concentrations exceeded recommended exposure limits . Personal protection Equipment : " Respiratory : Use an air-purifying respirator equipped with filters for protection against dusts and mists . 

# " Hand: Use cotton or canvas gloves. " Eye: Eye protection worn must be compatible with respiratory protection system employed. 

# Other Control Measures : " Use good industrial hygiene practices. Wash hands and face before eating and drinking. 

# 9 . Properties " Appearance : White powder " Odor : None 

# " pH : Not applicable Page (frage-2) 

# 7-j

## p. 21 

# " Boiling point : Not applicable " Melting point : 1890 °C " Specific Gravity : 3.2 " Solubility in water : Insoluble " Vapor density : Not applicable " Vapor Pressure : Not applicable " Volatile by Volume : 0% 

# 10 . Reactivity Information Conditions To Avoid: Not applicable. Hazardous Polymerization: 

# Hazardous Polymerization will not occur. Hazardous Decomposition: Hazardous decomposition will not occur. Stability: This material is stable under normal operating conditions. 

# 11 . Health / Toxicity Information Health Hazards Effects ofAcute Exposure " Inhalation: Inhalation of dust can cause irritation of the nose, throat, and lungs. " Eye Contact: Like any foreign body, particles can cause mechanical irritation. 

# Skin Contact: This material can cause irritation if not promptly washed fromthe skin. Skin Absorption: This product is not expected to be absorbed though intact skin. Ingestion: This material is not expected to produce adverse effects. Effects of Chronic Over Exposure: 

# As with any nuisance dust, long-termexposure to concentrations above the recommended exposure limits may overload the lung clearance mechanismand cause adverse lung effects and shortness of breath. Listed as a suspected or known carcinogen on: - IARC :No Medical Conditions Aggravated: Respiratory disorders. Toxicity Information Not applicable Page"~ (Page-3) 

# a/

## p. 22



# 12. Environmental Hazards: Environmental Hazards: " None known. 

# 13. Disposal Considerations " Dispose of in accordance with local, state, and federal regulations. Use a licensed waste handler. 

# 14. Transportation Shipping Name :MagnesiumSilicate Label :Not applicable Hazard Class :Not regulated Packing Group :Not applicable UN# :Not applicable 

# 15. Regulatory Information Chemical Inventories: In compliance denotes that all components are on the inventory or exempt . European Inventory :In Compliance Japanese Inventory :In Compliance Korean Inventory :In Compliance 

# Other Regulatory Information: No data available End of MSDS

## p. 23

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## p. 25

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## p. 26

## p. 27

Page

## p. 28

Paae

# Inventory Expert Service

A di-isien of the American Chemical Society



## INVENTORY EXPERT SERVICE REPORT

YES-ORDER NMER: 86974 REGISTRY NtTBBERo C

CA INDEX NAM 

# 7 Phone : ROD-631-1894, 614-447-3270

Fax ; 614-447-3747 E-maH: answers@cas.org Internet: http:llw-w

.as.org/Suppondciicnc.hcml



## Plaare yZint the ibave CA Iadex Name oss the appiopriate page of your PM .



## eooln If thin boae ~,s checked, CAS has made corraaeioa(a) markvfl in rod to your TES order . Please make the smn correction(B) to yoltr pM before rn4mittiag it to the Epik .

2540 Olanqmgy Rl~cr Road " PO . Box 1343 " CWuntbA Ohio 43210 .03)4 

## 5dD Lvtc L14 qTe Ydd 0=L0 NOW SO/9T/SO

# PreManufacture Notice and

Notice of Commencement Forms EPA . Form7710-25 (Rev. 5-95) EPA Form

7710-56 (Rev. -96)



# Installation and Use .Instructions MS Word 6

. Ofor Windows

U.S. EPAApproved December 12,1996 by Anthony Cheatham TSCA Data Administration Section 

# CM ° ResponsibieCare' APublic Commitment

## p. 31